Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the determination of the Utah State Tax Commission that the Property Tax Division correctly followed the requirements of the Aircraft Valuation Law, Utah Code 59-2-201 subsection 4, in determining the 2017 value of Delta Air Lines' aircraft, holding that Salt Lake County failed to demonstrate that the Law, as applied to Delta's 2017 assessment, violated the fair market value provision of the Utah Constitution.For tax year 2017, the Division valued Delta's aircraft according to section 59-2-201's preferred methodology. The County appealed, arguing that the valuation did not reflect the fair market value of Delta's aircraft, in violation of the Utah Constitution. The Commission upheld the assessment, concluding that the County did not establish that the Legislature's preferred method of valuation did not reasonably reflect fair market value. The Supreme Court affirmed, holding that the Aircraft Valuation Law was not unconstitutional as applied by the Commission to assess the value of Delta's aircraft for tax year 2017. View "Salt Lake County v. Utah State Tax Commission" on Justia Law

The Supreme Court held that Ark. Code Ann. 12-9-301, which provides immunity from both suit and liability for certain officials "except to the extent that they have be covered by liability insurance," does not apply to a federal cause of action brought under 42 U.S.C. 1983 but does apply to a state claim brought under the Arkansas Civil Rights Act.Plaintiff filed a complaint against the Benton School District, a principal in the strict (Lori Bacon), and an assistant superintendent (Lisa Gattis). The district court concluded that all Defendants were liable under section 1983 and the Arkansas Civil Rights Act for violating Plaintiff's rights to free speech and to petition the government under the First Amendment. The court granted Bacon and Gattis's motion for summary judgment on qualified immunity grounds but determined that their motion was limited to the extent they were covered by liability insurance. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) section 21-9-301 does not impact a claim brought under section 1983; and (2) the circuit court correctly ruled that section 21-9-301 immunity applies to claims arising under the Arkansas Civil Rights Act. View "Benton School District v. Greer" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that because Defendant's license plate cover violated Iowa Code 321.37 it was reasonable for Iowa State Patrol troopers to stop his SUV, the stop was not unconstitutional, the exclusionary rule did not apply, and there were no grounds to suppress evidence from the stop.Because Defendant's rear license plate was shrouded with a tinted plastic cover troopers found it difficult to read the plate. The troopers stopped Defendant to warn him that the cover violated Iowa law and during the stop uncovered evidence leading to Defendant's charges for operating while intoxicated and child endangerment. The district court granted Defendant's motion to suppress, concluding that the traffic stop was unconstitutional. The Supreme Court reversed, holding (1) the traffic stop was constitutional because the license plate cover violated an Iowa traffic statute; and (2) therefore, the district court erred in suppressing evidence from the stop. View "State v. Griffin" on Justia Law

The Supreme Court affirmed the judgment of the district court ordering reinstatement of D.H.'s firearm rights, holding that there was no error on the part of the district court.After D.H. attempted suicide in 1995 a mental health board obtained a mental health commitment. As a result of D.H.'s commitment, federal and state statutes restricted his rights to purchase and possess firearms. In 2011, the Legislature enacted Neb. Rev. State. 71-963, which created a procedure whereby those subject to firearm restrictions resulting from a mental health-related commitment or adjudication could petition to have those restrictions removed. D.H. filed a motion to remove his firearm restrictions under section 71-963. The Mental Health Board of the 10th Judicial District of Nebraska denied the petition. The district court initially affirmed the denial but, upon reconsideration, granted the petition. The Supreme Court affirmed, holding that the district court did not commit an error of law or abuse its discretion in sustaining D.H.'s motion to reconsider, alter, or amend. View "In re Interest of D.H." on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment for Defendant on Plaintiff's claims for disability discrimination, in violation of Title I of the Americans with Disabilities Act (ADA) and Mass Gen. Laws ch. 151B, and for age discrimination, in violation of Mass. Gen. Laws ch. 151B, holding that there was no error.The district court (1) concluded that Plaintiff had failed to carry her burden to make out a prima facie case that she was a "qualified individual" under the ADA and thus also failed to do so under chapter 151B; and (2) concluded that Plaintiff had failed to demonstrate a genuine dispute of material fact as to whether Defendant's proffered reason for her termination was pretextual. The First Circuit affirmed, holding (1) Defendant was entitled to summary judgment on Plaintiff's ADA and Mass. Gen. Laws ch. 151B disability discrimination claims; and (2) the district court did not err in granting summary judgment for Defendant on Plaintiff's claim of age discrimination under Mass. Gen. Laws ch. 151B. View "Der Sarkisian v. Austin Preparatory School" on Justia Law

The Supreme Court affirmed the order of the circuit court finding that Petitioner violated the conditions of his supervised release and revoking his supervised release and sentencing him to a two-year term in prison, holding that United States v. Haymond, 588 U.S. __ (2019), does not apply to a supervised release revocation pursuant to W. Va. Code 61-12-26 because section 61-12-26 does not require a mandatory minimum sentence upon revocation.Specifically, the Supreme Court held (1) the revocation of Petitioner's supervised release pursuant to W. Va. Code 62-12-26 did not violate Petitioner's constitutional rights; (2) the circuit court did not err by denying Petitioner's motion to dismiss the petition or by sentencing Petitioner to a term of imprisonment without holding a jury trial when revoking his supervised release; and (3) the circuit court did not clearly err in finding by clear and convincing evidence that Petitioner conspired to deliver crack cocaine, in violation of conditions of his supervised release. View "State v. White" on Justia Law

In 2015, the International Agency for Research on Cancer (IARC) identified glyphosate as “probably carcinogenic” to humans. That conclusion is not shared by a consensus of the scientific community. As a result, Certain businesses whose products expose consumers to glyphosate were required to provide a Prop 65 warning that glyphosate is a carcinogen. Plaintiffs, a coalition of agricultural producers and business entities, asserted that Prop 65’s warning violated their First Amendment rights to be free from compelled speech. The district court granted summary judgment in favor of Plaintiffs.   The Ninth Circuit affirmed. The panel concluded that the government’s proposed Prop 65 warnings as applied to glyphosate were not purely factual and uncontroversial and thus were subject to intermediate scrutiny. The proposed warning that “glyphosate is known to cause cancer” was not purely factual because the word “known” carries a complex legal meaning that consumers would not glean from the warning without context, and thus the word was misleading. As to the most recent warning proposed by the California Office of Environmental Health Hazard Assessment (OEHHA), the panel held that the warning still conveys the overall message that glyphosate is unsafe, which is, at best, disputed. The panel held that because none of the proposed glyphosate Prop 65 warnings were narrowly drawn to advancing California’s interest in protecting consumers from carcinogens, and California had less burdensome ways to convey its message than to compel Plaintiffs to convey it for them, the Prop 65 warning requirement as applied to glyphosate was unconstitutional. View "NAWG, ET AL V. ROB BONTA, ET AL" on Justia Law

In 1970, Michigan voters approved Proposal C, amending Article VIII, section 2 of Michigan’s constitution: “No public monies or property shall be appropriated or paid or any public credit utilized, by the legislature or any other political subdivision or agency of the state directly or indirectly to aid or maintain any private, denominational or other nonpublic, pre-elementary, elementary, or secondary schools.” The plaintiffs allege that Proposal C was spurred by the legislature’s passage of 1970 PA 100, which “allowed the Department of Education to purchase educational services from nonpublic schools in secular subjects,” and authorized $22 million in spending during the 1970-71 school year. Plaintiffs allege that “nonpublic schools” meant “religious schools”; opposition to 1970 PA 100 resulted in Proposal C. In 2000, Michigan voters rejected a ballot initiative that would have amended the section to authorize “indirect” support of non-public school students and create a voucher program for students in underperforming public school districts to attend nonpublic schools.Plaintiffs brought unsuccessful free exercise claims, alleging they have funded Michigan Education Savings Program plans and wish to use those plans to pay for their children’s religious school tuition. The Sixth Circuit affirmed the dismissal of their equal protection claim that section 2, while facially neutral, creates a political structure that unconstitutionally discriminates against religion because religious persons and schools cannot lobby their state representatives for governmental aid or tuition help without first amending the state constitution. View "Hile v. State of Michigan" on Justia Law

In 2011, Lutter began working for Essex County, in a bargaining unit represented by JNESO. Under Supreme Court precedent (Abood), a public-sector union could charge fees from non-union members whom the union represented. New Jersey law permitted public-sector unions to deduct an "agency fee." Lutter joined JNESO and authorized payroll deductions of her union dues.In 2018, New Jersey enacted the Workplace Democracy Enhancement Act (WDEA): a union member could revoke authorization for payroll deductions only during the 10 days following the anniversary of his employment start date. Previously, union members could give notice of revocation at any time. A month later, the Supreme Court (Janus) held that the First Amendment prohibits public-sector unions from collecting agency fees from nonmembers without their clear and affirmative consent. Under WDEA Janus would have to wait nearly a year to revoke her payroll deduction authorization. In July 2018, she nonetheless requested that deductions of her union dues cease and resigned from JNESO. Essex County deducted Lutter's union dues for 10 months.Lutter filed suit, 42 U.S.C. 1983. JNESO sent her a check in the amount of the contested union dues plus interest. She did not cash or deposit that check. The district court dismissed the case. The Third Circuit affirmed in part. The check did not moot her damages claims against JNESO but Lutter, as a non-union member no longer subject to payroll deductions, lacks standing for her claims against the other parties and for her additional requests for relief against JNESO. View "Lutter v. Jneso" on Justia Law

In these consolidated appeals brought in connection with a federal investigation of an organization that operated in Puerto Rico's prisons and was allegedly involved in carrying out murders-for-hire and trafficking drugs, the First Circuit held that one challenge raised on appeal required a limited remand to the district court and that Appellants were not entitled to further relief.Each of the six appellants in this case was convicted of conspiracy to violate the Racketeer Influenced and Corrupt Organization Act and conspiracy to possess with intent to distribute a controlled substance. The First Circuit granted a limited remand and otherwise affirmed, holding (1) the argument brought by three appellants that hearsay statements by alleged coconspirators were admitted into evidence at trial, in violation of United States v. Petrozziello, 548 F.2d 20 (1st Cir. 1977), required a remand for further fact-finding as to whether the statements were made in furtherance of the alleged conspiracy; (2) Appellants' sufficiency of the evidence challenges failed; and (3) Appellants were not entitled to relief on their remaining allegations of error. View "United States v. Ramos-Baez" on Justia Law